Climate rules should maintain “all of the above” approach

The U.S. Environmental Protection Agency (EPA) certainly has a
critical task before it to strike the balance between the president’s
climate action plan and what is feasible to ask utilities and industry
to comply with, especially in light of the mountain of other rules the agency has pending. However, it is important for the agency to work within the context of the administration’s stated focus on an “all of the above” energy strategy and to not disadvantage one solution or another.

The paper and wood products manufacturing industry’s primary fuel source – biomass manufacturing residuals – provide greenhouse gas (GHG) reduction benefits equivalent to removing 40 million cars from the road. EPA is currently drafting an accounting framework for biogenic carbon dioxide (CO2) emissions that we believe should establish our industry’s use of biomass as carbon neutral and distinguish biomass emissions from fossil fuel emissions; this framework would then guide development of regulations such as the Tailoring Rule and prevention of significant deterioration and Title V air permitting rules. Until this framework and the subsequent rules are finalized, facilities are in a holding pattern for investment, perpetuating an atmosphere of uncertainty.

That said, what EPA does today with regard to utility rules affects our facilities, potentially driving up cost for facility ratepayers and setting precedent for industry regulation down the road. We already face a tremendous number of air regulations from boiler maximum achievable control technology to national ambient air quality standards to new source performance standards. Some of the actions being proposed, such as the electric generating unit rules, are based on the availability of yet undemonstrated technology. If passed, this rule would selectively disadvantage coal, taking an important domestic fuel out of the mix for the foreseeable future and raising costs for our facilities that need to purchase electricity. With billions in additional compliance costs on the way for other regulations, it just adds unnecessarily to the cumulative burden that our industry is already facing.

EPA and the administration should focus on ensuring rules are set using sound science, like treating biogenic emissions as carbon neutral, but also with an eye to the social and economic impacts those rules could have – not just environmental.